SEC Company Response from ENERPLUS RESOURCES FUND (CIK 0001126874) — Nov 22, 2005
ENERPLUS RESOURCES FUND (CIK 0001126874)
Date: Nov. 22, 2005 · CIK: 0001126874 · Accession: 0001279569-05-001054
AI Filing Summary & Sentiment
Letter
United States Securities and Exchange Commission Division of Corporate Finance Re: Enerplus Resources Fund Form 40-F for the Year ended December 31, 2004 Accounting for Stock Based Compensation File No 1-15150
Dear Ms. Eisen;
We are disappointed in the position taken by the SEC staff in your letter of October 18, 2005. Without agreeing with your interpretation of GAAP, we will work towards preparing and delivering the analysis that you have requested.
As discussed in our telephone call today, we require more than 10 days to prepare the analysis that you have requested.
·
Enerplus is a 40F Filer and our next filing is not until March 2006;
·
As discussed in our submissions, we do not use the valuation models in managing our business, so we need to retain experts and familiarize ourselves with the various model alternatives;
·
There are a number of management estimates and qualitative judgments that we need to make in order to fit our circumstances into the modeling formulas. It will take time to make these judgment calls;
·
We want our auditors, Deloitte & Touche, to review our findings and methodology.
We acknowledge that you would like a response by November 15, 2005 and will work diligently and in good faith to make that deadline. However, I would like to note that this is a complex issue as evidenced by the time it took for you to respond to our first submission. If, at any time, it appears that we will be unable to meet that deadline, we will contact you immediately and discuss the circumstances and nature of the delay.
- 2 -
Thank you for your consideration.
Sincerely
/s/
Robert J. Waters
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CORRESP
1
filename1.htm
CORRESP
Robert
J. Waters
Sr.
Vice President & Chief Financial Officer
Enerplus
Resources Fund
The
Dome
Tower
3000,
333-7th Avenue
SW
Calgary,
Alberta T2P
2Z1
Tel
403.298.1295
Fax
403.298.2299
www.enerplus.com
October
19, 2005
BY
FAX: 202-772-9220
Ms.
Sandy Eisen
United
States Securities and Exchange Commission
Division
of Corporate Finance
100
F Street N.E.
Washington,
D.C. 20549
Re:
Enerplus
Resources Fund
Form
40-F for the Year ended December 31, 2004
Accounting
for Stock Based Compensation
File
No 1-15150
Dear
Ms. Eisen;
We
are disappointed in the position taken by the SEC staff in your letter of
October 18, 2005. Without agreeing with your interpretation of GAAP,
we will work towards preparing and delivering the analysis that you have
requested.
As
discussed in our telephone call today, we require more than 10 days to prepare
the analysis that you have requested.
·
Enerplus
is a 40F Filer and our next filing is not until March 2006;
·
As
discussed in our submissions, we do not use the valuation models in
managing our business, so we need to retain experts and familiarize
ourselves with the various model alternatives;
·
There
are a number of management estimates and qualitative judgments that
we
need to make in order to fit our circumstances into the modeling
formulas. It will take time to make these judgment calls;
·
We
want our auditors, Deloitte & Touche, to review our findings and
methodology.
We
acknowledge that you would like a response by November 15, 2005 and will work
diligently and in good faith to make that deadline. However, I would like
to note that this is a complex issue as evidenced by the time it took for you
to
respond to our first submission. If, at any time, it appears that we will be
unable to meet that deadline, we will contact you immediately and discuss the
circumstances and nature of the delay.
-
2 -
Thank
you for your consideration.
Sincerely
/s/
Robert J. Waters
Robert
J. Waters
c:
April Sifford, Branch Chief, United States
Securities and Exchange Commission
Gordon Kerr, President and CEO
Robert Normand, Chairman, Audit Committee
Ward Zimmer, Deloitte & Touche LLP